Category: OECD

The Organization for Economic Cooperation and Development on Monday rolled out a sweeping set of final recommendations to battle offshore tax avoidance costing countries across the globe billions of dollars a year. A group of almost three dozen advanced economies, the OECD kicked off its efforts two years ago, seeking...

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and...

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the...

David Gauke, the Financial Secretary to the UK Treasury, has spoken out in support of the international tax measures being adopted by the UK, and pushed the idea of diverted profits taxes. Speaking at the American Enterprise Institute in Washington DC on September 29, 2015, Gauke said recent reforms have...

Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals...

The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases...

On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member...

By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the...

The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip...

The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on...

Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless...

EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in...

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based...

On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables...

Oct 1 Germany is not ruling out the introduction of tax breaks for companies on revenue generated from patented or licensed research, a senior official said on Thursday. The government has repeatedly said it would consider introducing so-called patent boxes if there were no progress towards fair tax competition at...

Quebec — Tax havens are depriving Quebecers of at least $1.5 billion a year, said Québec solidaire MNA Amir Khadir on the opening day of parliamentary hearings on the worldwide phenomenon. The National Assembly’s public finances committee decided last June to dedicate several days this fall to the study of...

On 16 June 2015, the Department of International Tax Cooperation of the Cayman Islands (the “DITC”) announced that it would be implementing the CRS into domestic law. The draft Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 are currently under review and it is expected that these...

A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater...

WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District...

The OECD/ G20 Action Plan on Base Erosion and Profit Shifting (BEPS) published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner. Actions 8-10 of the BEPS Action Plan relate to a number of closely related topics. These include the development of rules to prevent BEPS...

The Yomiuri Shimbun The Organization for Economic Cooperation and Development will establish a comprehensive package of international rules to clamp down on tax saving tactics by multinational companies, The Yomiuri Shimbun learned Tuesday. The pillar of the package is to halt tax-saving practices like unrealistic lending and borrowing as well...

On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the...

Ireland ‘needs to end its dependence on multinationals’ Ireland needs to end its dependence on multinationals and broaden its support to indigenous businesses, tax experts said yesterday, as they called for a €1 billion package to boost entrepreneurship. “While Irish tax policy must ensure that Ireland remains a competitive location...

At the request of the G20, OECD published its Action Plan on addressing ‘base erosion and profit shifting’ (BEPS) in July 2013, wherein it identified 15 actions on BEPS for future work, intending to carry out fundamental changes to the international tax standards. Amongst other, Action 7 deals with ‘preventing...

Tax treaties serve to reduce or eliminate double taxation which, if unrelieved, would be a significant barrier to cross-border trade and investment. At the same time, there was need felt to protect against granting of treaty benefits in inappropriate circumstances. In this background, the work of the OECD and G20...

China will be at the forefront of embracing the emerging international tax rules to combat base erosion and profit shifting, known as BEPS, as it shifts toward becoming a “capital-export” country, said senior EY executives. “China is not going to be a laggard. A lot of small developing countries are...

Tax laws are lagging behind the digital economy. As changes in the digital realm continue to outpace the speed at which legislators can work, and borders increasingly blur because of the internet, SA needs to play catch-up when it comes to tax. Currently, the only digital tax of any consequence...

In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim...

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in...

The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in...

China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular...

One in five corporations with annual profits greater than $100 million paid no tax last year, the Australian Tax Office has revealed. Michael Cranston, one of the ATO’s deputy commissioners, revealed the figure to a Senate hearing into corporate tax avoidance. Corporations avoid paying tax by what is euphemistically called...

Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the...

If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying...

Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition...

The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against...

On September 17, 2015, the Canadian Border Services Agency (“CBSA“) released a revised D-Memorandum D13-4-5, “Transaction Value Method for Related Persons” (the “Memorandum“), addressing the impact of income tax transfer pricing on the value for duty to be declared on goods imported into Canada. This new guidance will have a...

India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,...

In 2013, the Organisation for Economic Cooperation and Development (OECD) released a series of proposed tax measures for eliminating corporate tax structures that shift profits to foreign jurisdictions. This corporate tax practice is commonly referred to as base erosion and profit shifting or BEPS. Towards this, the OECD and G20...

Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common...

Pretoria – The constant stream of new data requirements by the South African Revenue Service from South Africa’s major banks is costing the sector millions of rand and affecting the economy and banking costs. Tax heads at the banks raised questions during the recent Tax Indaba in Sandton about the...

Bloomberg BNA’s first transfer pricing conference in Asia—the latest offering in our Global Transfer Pricing Conference series with Baker & McKenzie—could not have been better timed. The day the conference opened, Sept. 17, China issued a revised draft circular on transfer pricing that completely changed the game for multinational companies...

Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that...

Prime Minister Narendra Modi is scheduled to attend the UN Sustainable Development Summit as part of his second visit to the United States. INDIA IS likely to talk on the increased global efforts against tax avoidance and tax evasion at the United Nations later this month. Prime Minister Narendra Modi...

NEW YORK, NY–(Marketwired – September 23, 2015) – With the global implementation of FATCA and anticipation of the Common Reporting Standard (CRS), legal and compliance professionals within the banking industry have never seen such a regulatory overload and focus on ensuring proper compliance processes. As these multi-national regulations become implemented...

The tax office is beefing up efforts to catch international tax cheats by swapping banking information with US authorities. Details of more than 30,000 financial accounts worth over $5 billion held in Australia by US citizens will be provided to US Internal Revenue Services under the first wave of transparency...

BHP Billiton has defended the use of a Singapore marketing hub to minimise its tax payments, saying most of its Australian profits continue to be taxed in its home country. The resources giant, which came under fire earlier this year over allegations of tax avoidance, says its global adjusted effective...